EAA requirements for audiovisual media access

In brief

The European Accessibility Act covers services that provide access to audiovisual media services (Article 2(2)(b)) and consumer terminal equipment used to access them (Article 2(1)(d)). Annex I, Section IV sets two requirements for the services.

The Directive is about the access: programme guides, players and transmission of access services such as subtitles and audio description.

Requirements for access services (Section IV, point B)

• Provide electronic programme guides that are perceivable, operable, understandable and robust, and that indicate which accessibility features are available.
• Make sure access services, such as subtitles for the deaf and hard of hearing, audio description, spoken subtitles and sign language interpretation, are fully transmitted with adequate quality, are synchronised with sound and video, and allow users to control their display and use.

Check the exact wording of Annex I before you cite it.

Devices used to access audiovisual media

Consumer terminal equipment with interactive computing capability that is used to access audiovisual media services is a product under Article 2(1). Annex I, Section I requires it to make the accessibility components supplied by the media service provider available to users, so they can access, select, control and personalise them and pass them to assistive devices.

What this Directive does not decide

The Directive concerns services that provide access to audiovisual media services. Whether and how a programme itself must carry subtitles or audio description is a matter for other rules, such as national audiovisual media law. Check those separately.

Pre-recorded media published before 28 June 2025

Article 2(4) excludes pre-recorded time-based media published before 28 June 2025 from the requirements for website and app content. See content exclusions for what is and is not covered.

Where to start in the checklist

For web and app players and media pages, these criteria cover the usual gaps. The mapping is practical guidance, not a clause reference:

• Captions for pre-recorded media and captions for live media.
• Audio description or a media alternative and audio description for pre-recorded video.
• Keyboard access and name, role, value for player controls.
• Pause, stop, hide and three flashes or below threshold.

What to do

• Check the programme guide. It must work with assistive technology and show which accessibility features each programme has.
• Test access services end to end. Subtitles, audio description and sign language must be transmitted in full, synchronised, and controllable.
• Test the player. Controls need keyboard access, names and visible focus.
• Check device support. Devices must pass accessibility components on to the user.
• Check national media rules. They may set content-level duties separately.

Common mistakes

• Only captioning the video. The guide, the player and the controls are also part of the service.
• Access services that drift out of sync. Section IV asks for synchronisation with sound and video.
• No way to switch features on. Users must be able to control the display and use of access services.
• Assuming the Directive sets caption quotas. It covers the access, not the content duties.
• Ignoring the device layer. Terminal equipment must make the accessibility components available.

Sources

• Directive (EU) 2019/882, European Accessibility Act (EUR-Lex), opens in a new tab

This page is for informational purposes only and is not legal advice. For binding requirements, refer to the official text of the European Accessibility Act (Directive (EU) 2019/882) and to the national law of the Member State where you operate.